On July 8, 2014, the Manzanar Committee submitted its official comments to the Inyo County Planning Department and Board of Supervisors in response to their Notice of Preparation for the Program Environmental Impact Report for their 2013 Renewable Energy General Plan Amendment (REGPA).
In their initial draft of this amendment, the County would have opened the Owens Valley, from Independence south to Lone Pine, east of U.S. Highway 395, to large-scale renewable energy facilities that would intrude upon the viewshed of the Manzanar National Historic Site. Along with tribal organizations in the Owens Valley and the Owens Valley Committee, the Manzanar Committee fought to have this area removed from consideration, to protect both the Owens Valley and its residents, along with the Manzanar National Historic Site.
After months of political pressure, the Board of Supervisors removed the Owens Valley from consideration as part of the 2013 REGPA in their latest draft (June 2014), which is now moving to the next stage, the drafting of a Program Environmental Impact Report (PEIR).
Our comments for the PEIR below, written by Manzanar Committee Co-Chair Bruce Embrey, closely mirror our initial comments on the 2013 REGPA.
July 8, 2014
County of Inyo
P.O. Drawer L
Independence, CA 92526-0611
RE: Notice of Preparation (NOP) – Program Environmental Impact Report (PEIR) – General Plan Amendment 2013-02/Inyo County Renewable Energy
The Manzanar Committee, which sponsors the annual Manzanar Pilgrimage and Manzanar At Dusk programs, and has played a key role in the preservation, protection and creation of the Manzanar National Historic Site, is vehemently opposed to any development that would interfere with the operation, goals and purpose of the Manzanar NHS, including forever marring its viewshed. As such, we are pleased that the Owens Valley is not included as a Solar Energy Development Area (SEDA) in the June 2014 draft of the 2013 Renewable Energy General Plan Amendment (REGPA) and we strongly urge the County of Inyo to forever protect this area from any large-scale renewable energy development.
In addition to protecting the cultural resources in the Owens Valley and the viewshed of the Manzanar NHS, such development in the Owens Valley, would make no sense, given that your economy is based primarily on tourism. After all, visitors are attracted to the Owens Valley because of its mostly pristine, open lands, along with forest areas, and other outdoor wonders. Tourism would suffer greatly if massive renewable energy facilities are built in the area.
We have also noted that some in Inyo County believe that large-scale solar energy projects would bring increased economic development. But if the Los Angeles Department of Water and Power’s (LADWP) proposed Southern Owens Valley Solar Ranch (SOVSR) is any indication of how wrong such beliefs are, Inyo County must not buy into this fallacy. After all, according to LADWP’s Draft Environmental Impact Report, the project would employ approximately 350 temporary workers, and up to ten permanent employees.
As such, in terms of providing employment opportunities for Inyo County residents, the SOVSR would generate some temporary jobs during construction of the project (LADWP stated it would take approximately five years to finish construction), but no more than ten permanent jobs to operate and maintain the facility. Does that sound like it is worth destroying a huge swath of the Owens Valley, given that, as I stated above, your economy is based on tourists, who are attracted to the Owens Valley because of the beauty of its open spaces and pristine lands?
Before anyone gets the wrong idea, let me state for the record that the Manzanar Committee is not opposed to solar energy, or other renewable energy sources. In fact, we applaud Inyo County’s support of projects that would help us move away from fossil fuels. However, this brings up another reason why the Owens Valley must be protected from large-scale solar energy development. To be sure, placing massive solar facilities in the Owens Valley is the wrong choice while other options exist. In fact, centralized, industrial solar facilities are not a wise use of resources at this time, as centralized solar farms are less efficient and more expensive than distributed, rooftop solar systems.
Distributed solar produces energy directly in the market where it is consumed. There is no need for expensive, massive transmission lines and distribution infrastructure. For example, Los Angeles can easily generate incredible amounts of energy to power its homes and businesses from rooftop solar projects (source: report by Los Angeles Business Council/UCLA Luskin Center for Innovation). Furthermore, by its own admission, the LADWP will pay homeowners in the Owens Valley substantially less than homeowners here in Los Angeles per kilowatt hour (source: LADWP).
Not only would permitting large-scale solar energy development open the door for such ill-conceived, large-scale development in the Owens Valley, but it would also put a major crimp in the ability of the Manzanar NHS to accurately tell the story of the 11,070 Americans of Japanese ancestry, and their immigrant parents who were prevented from naturalizing due to racist laws, who were unjustly incarcerated there during World War II.
The natural environment surrounding Manzanar is an indispensable element in understanding what those incarcerated in America’s concentration camps experienced. The fact that our government chose to incarcerate over 110,000 persons of Japanese ancestry—2/3rds of whom were native-born American citizens—and to place them in remote, desolate, largely uninhabitable locations is key to understanding what our families and our community were subjected to. In fact, one of the key reasons Manzanar has been such a successful National Park is that the site, and the surrounding area, was not marred by development, and has remained largely untouched since World War II.
In fact, the very idea that any land in or around the Manzanar NHS could be used for a massive solar energy generating facility would not harm the ongoing efforts to preserve and understand the tragedy of justice that occurred there is simply beyond insensitive, and it’s not just insensitive to the Japanese American community, the survivors of America’s concentration camps and their families. That gross insensitivity extends to the efforts of the National Park Service, and others who have worked so hard to bring this brief, but essential, part of American History to light.
Indeed, not only has the Manzanar NHS been a huge success, but it is also a significant contributor to Inyo County’s economy, with annual visitation topping 82,000 people. But their experience will be greatly diminished if large-scale renewable energy development is permitted within Manzanar’s viewshed. Such development would severely hamper the efforts of National Park staff at Manzanar to accurately tell the story of those who were incarcerated there—as stated above, they would no longer be able to accurately show the desolation aspect of the story, which is essential to understanding it. Moreover, to allow such development would also greatly disrespect and dishonor those who were incarcerated there, people who were, in fact, Inyo County residents who expect and deserve much better from their former home.
2014 marks the tenth anniversary of the opening of the visitor’s center at the Manzanar National Historic Site. Over one million people have visited the site since 2000. This year also marks the 50th anniversary of the Civil Rights Act. Our country has come a long way since 1964, and we hope that as we celebrate the advances we’ve made in the area of civil rights, the concerns of those Americans who were denied those rights simply because of their ancestry are not swept aside and ignored.
Once again, we strongly urge Inyo County to do its part by doing everything in its power to protect the Owens Valley from large-scale renewable energy development in perpetuity.
The Manzanar Committee is dedicated to educating and raising public awareness about the incarceration and violation of civil rights of persons of Japanese ancestry during World War II and to the continuing struggle of all peoples when Constitutional rights are in danger. A non-profit organization that has sponsored the annual Manzanar Pilgrimage since 1969, along with other educational programs, the Manzanar Committee has also played a key role in the establishment and continued development of the Manzanar National Historic Site. You can also follow the Manzanar Commitee on Facebook, Twitter, Instagram, Pinterest and YouTube.
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